On Sept. 8, 2016 the final rule Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers was published in the Federal Register. By Nov. 16, 2017, providers and suppliers must be in compliance.

“It’s getting old,” says Donald J. Jones, FACHE, administrator for Fayette Medical Center, about the looming Medicaid shortfall recently decided by the Alabama legislature. Every year the cycle repeats, he says, and every year, the state finds a way. “But it feels different this year. I’m concerned.”

In January, Alabama Medicaid named eleven organizations as probationary Regional Care Organizations (RCOs). By October of next year, the plan is for these nonprofit RCOs to manage the care of just over 600,000 qualifying Medicaid patients in the state.

Alabama recently passed into law two separate bills to develop at-risk provider-driven Medicaid care management programs. The first bill, passed in 2013, created the Regional Care Organization (RCO) system. See Alabama Code § 22-6-150 et seq. This legislation was developed upon the recommendation of the Medicaid Study Commission, which was created by the Governor who appointed members representing a range of providers, insurers, consumer advocacy groups, and state government officials.

On May 17, 2013, Governor Bentley signed into law Act 2013-261, Ala. Code § 22-6-150 et. seq. which changed the Alabama Medicaid program from a fee-for-service program to a managed care program creating Regional Care Organizations ("RCOs") to serve as the conduit for care to Medicaid beneficiaries.

On April 4, another legal layer to introducing Regional Care Organizations (RCO) into Alabama officially hit the books. Senate Bill 459 set the stage for publication of rules and other actions that will transform the state’s Medicaid Agency from a fee-for-service system into a capitated, coordinated care model.